Werner G. Smith logo

Werner G. Smith, Inc.

1. INTRODUCTION & PURPOSE

This Code of Business Ethics establishes the standards of conduct expected of all employees, contractors, supervisors, and representatives of Werner G. Smith, Inc. It reflects our commitment to operating with integrity across every level of our manufacturing operations — from the shop floor to the executive suite.

Everyone at Werner G. Smith, Inc. is responsible for understanding and upholding this Code.
Violations may result in disciplinary action, up to and including termination.

2. CORE VALUES

Safety First — We never compromise on the health and safety of our people, products, or communities.

Integrity — We are honest and transparent in all business dealings, and we stand behind the quality of our work.

Accountability — We take ownership of our actions and the outcomes of our work.

Respect — We treat every person with dignity, regardless of their role or background.

Quality — We take pride in our craftsmanship and hold ourselves to the highest production standards.

Sustainability — We operate responsibly, minimizing our environmental footprint and preserving resources for future generations.

3. WORKPLACE SAFETY & HEALTH

The safety of our workforce is our highest obligation.

• All employees must comply with OSHA regulations and the Company’s safety policies at all times.

• Personal protective equipment (PPE) must be worn as required in designated areas.

• Employees must report all injuries, near-misses, unsafe conditions, and equipment hazards to their supervisor immediately.

• No one is authorized to bypass, disable, or override safety equipment or procedures.

• Working under the influence of alcohol or illegal substances is strictly prohibited.

• Threats or acts of violence will not be tolerated and will result in immediate disciplinary action.

4. PRODUCT QUALITY & INTEGRITY

Our reputation depends on what we produce.

• All products must be manufactured in accordance with established specifications, quality standards, and applicable regulatory requirements.

• Employees must never knowingly produce, pass, or ship defective or non-conforming products.

• Quality defects, production errors, or suspected safety issues must be reported immediately through proper channels.

• Falsifying inspection records, test results, or production data is strictly prohibited and may constitute fraud.

• We comply with all applicable product safety laws, including labeling, certification, and reporting requirements.

5. EQUAL OPPORTUNITY & RESPECTFUL WORKPLACE

Werner G. Smith, Inc. is an equal opportunity employer. We prohibit discrimination or harassment based on race, color, religion, sex, national origin, age, disability, veteran status, or any other protected characteristic.

Harassment, bullying, or intimidation — whether verbal, physical, or electronic — will not be tolerated. All employees are entitled to a respectful work environment.

6. CONFLICTS OF INTEREST

Employees must avoid situations where personal interests conflict with their responsibilities to the Company. This includes:

• Ownership or financial interests in competitors, customers, or suppliers

• Accepting gifts, kickbacks, or payments from vendors or contractors

• Using Company information, equipment, or relationships for personal gain

• Hiring or supervising family members without prior disclosure and approval

Any potential conflict of interest must be disclosed promptly to your supervisor or Management.

7. GIFTS & ANTI-BRIBERY

Bribery and corruption have no place in our business.

• Employees may not offer or accept cash, gifts, or benefits intended to influence business decisions.

• Modest, occasional gifts of nominal value in the normal course of business are permissible but must be disclosed if they exceed $100.

• Payments of any kind to government officials require prior written approval from Management.

• Violations of anti-bribery laws (including the Foreign Corrupt Practices Act (FCPA) and applicable local laws) will be reported to authorities.

8. ENVIRONMENTAL RESPONSIBILITY

Manufacturing carries real environmental obligations. We take them seriously.

• All employees must comply with environmental laws and the Company’s environmental policies.

• Hazardous materials must be handled, stored, and disposed of according to applicable regulations (including EPA requirements).

• Spills, releases, or environmental incidents must be reported immediately.

• We are committed to reducing waste, conserving energy, and continuously improving our environmental performance.

• Falsifying environmental records or permits is a serious violation and may carry legal consequences.

9. SUPPLY CHAIN & VENDOR CONDUCT

We hold our suppliers and contractors to the same ethical standards we apply to ourselves.

• Vendors and contractors must comply with applicable labor laws, safety regulations, and human rights standards.

• We prohibit the use of forced labor, child labor, or human trafficking in our supply chain.

• Procurement decisions must be made on merit, value, and quality — not personal relationships or improper incentives.

• Employees involved in procurement must disclose any personal relationships with vendors.

10. COMPANY ASSETS & RESOURCES

Company equipment, tools, materials, vehicles, and facilities are provided for business use.

• Employees must handle Company property with care and promptly report any damage or theft.

• Theft or unauthorized removal of Company property — including materials, scrap, or products — is grounds for termination and may result in criminal prosecution and civil litigation.

• Company systems and communications (email, computers, networks) must be used responsibly and primarily for business purposes.

11. CONFIDENTIALITY & PROPRIETARY INFORMATION

Manufacturing processes, formulas, designs, customer lists, pricing, and operational data are Company assets.

• Employees must protect confidential information from unauthorized disclosure, both during and after employment.

• Proprietary information may not be shared with competitors, former employers, or third parties without authorization.

• Employees must comply with any non-disclosure or confidentiality agreements they have signed.

• Employees must not reveal tolling partners to anyone outside of the Company.

12. FINANCIAL INTEGRITY & ACCURATE RECORDS

• All financial transactions, time records, expense reports, and production data must be recorded accurately and honestly.

• No employee may falsify records, approve fictitious transactions, or submit fraudulent claims.

• Suspected fraud or financial misconduct must be reported to Management immediately.

• We cooperate fully with internal and external audits.

13. REPORTING CONCERNS & NON-RETALIATION

We encourage all employees to speak up when something doesn’t seem right.

How to Report:

• Speak directly with your supervisor or Management

Non-Retaliation: The Company strictly prohibits retaliation against any employee who reports a concern in good faith. Retaliation is itself a violation of this Code and will result in disciplinary action.

14. ENFORCEMENT & CONSEQUENCES

Violations of this Code will be investigated promptly and may result in:

• Verbal or written warning

• Mandatory retraining

• Suspension with or without pay

• Termination of employment

• Civil or criminal referral to appropriate authorities

Severity of consequences will reflect the nature of the violation and any prior disciplinary history.

ONE-PAGE QUICK REFERENCE

WERNER G. SMITH, INC. CODE OF BUSINESS ETHICS

★ OUR CORE VALUES

Safety First — Never compromise on health, safety, or community

Accountability — Own your actions and the outcomes of your work

Quality — Hold yourself to the highest production standards

Integrity — Honest and transparent in all business dealings

Respect — Treat every person with dignity

Sustainability — Minimize environmental impact; preserve resources

✔ ALWAYS DO

► Follow all safety rules, wear required PPE, and report injuries or hazards immediately

► Produce accurate, conforming products — report defects and never falsify quality records

► Treat all colleagues with dignity; harassment or discrimination will not be tolerated

► Record time, expenses, and production data honestly and accurately

► Protect confidential information, tolling partners, trade secrets, and proprietary formulas at all times

► Report concerns — you are protected from retaliation for good-faith reporting

✘ NEVER DO

► Bypass, disable, or override safety equipment or procedures — ever

► Knowingly pass, ship, or conceal defective or non-conforming products

► Accept or offer cash, gifts, or kickbacks intended to influence business decisions

► Use, share, or disclose confidential Company information without authorization

► Steal, misuse, or remove Company property, materials, scrap, or products

► Falsify any record — financial, environmental, quality, safety, or production

If something doesn’t seem right — speak up. Ask your supervisor or contact Management.

Violations may result in disciplinary action up to and including termination and legal referral.

Revised 5-7-26

WERNER G. SMITH, INC. CODE OF BUSINESS ETHICS

1. INTRODUCTION & PURPOSE

This Code of Business Ethics establishes the standards of conduct expected of all employees, contractors, supervisors, and representatives of Werner G. Smith, Inc. It reflects our commitment to operating with integrity across every level of our manufacturing operations — from the shop floor to the executive suite.

Everyone at Werner G. Smith, Inc. is responsible for understanding and upholding this Code.
Violations may result in disciplinary action, up to and including termination.

2. CORE VALUES

Safety First — We never compromise on the health and safety of our people, products, or communities.

Integrity — We are honest and transparent in all business dealings, and we stand behind the quality of our work.

Accountability — We take ownership of our actions and the outcomes of our work.

Respect — We treat every person with dignity, regardless of their role or background.

Quality — We take pride in our craftsmanship and hold ourselves to the highest production standards.

Sustainability — We operate responsibly, minimizing our environmental footprint and preserving resources for future generations.

3. WORKPLACE SAFETY & HEALTH

The safety of our workforce is our highest obligation.

• All employees must comply with OSHA regulations and the Company’s safety policies at all times.

• Personal protective equipment (PPE) must be worn as required in designated areas.

• Employees must report all injuries, near-misses, unsafe conditions, and equipment hazards to their supervisor immediately.

• No one is authorized to bypass, disable, or override safety equipment or procedures.

• Working under the influence of alcohol or illegal substances is strictly prohibited.

• Threats or acts of violence will not be tolerated and will result in immediate disciplinary action.

4. PRODUCT QUALITY & INTEGRITY

Our reputation depends on what we produce.

• All products must be manufactured in accordance with established specifications, quality standards, and applicable regulatory requirements.

• Employees must never knowingly produce, pass, or ship defective or non-conforming products.

• Quality defects, production errors, or suspected safety issues must be reported immediately through proper channels.

• Falsifying inspection records, test results, or production data is strictly prohibited and may constitute fraud.

• We comply with all applicable product safety laws, including labeling, certification, and reporting requirements.

5. EQUAL OPPORTUNITY & RESPECTFUL WORKPLACE

Werner G. Smith, Inc. is an equal opportunity employer. We prohibit discrimination or harassment based on race, color, religion, sex, national origin, age, disability, veteran status, or any other protected characteristic.

Harassment, bullying, or intimidation — whether verbal, physical, or electronic — will not be tolerated. All employees are entitled to a respectful work environment.

6. CONFLICTS OF INTEREST

Employees must avoid situations where personal interests conflict with their responsibilities to the Company. This includes:

• Ownership or financial interests in competitors, customers, or suppliers

• Accepting gifts, kickbacks, or payments from vendors or contractors

• Using Company information, equipment, or relationships for personal gain

• Hiring or supervising family members without prior disclosure and approval

Any potential conflict of interest must be disclosed promptly to your supervisor or Management.

7. GIFTS & ANTI-BRIBERY

Bribery and corruption have no place in our business.

• Employees may not offer or accept cash, gifts, or benefits intended to influence business decisions.

• Modest, occasional gifts of nominal value in the normal course of business are permissible but must be disclosed if they exceed $100.

• Payments of any kind to government officials require prior written approval from Management.

• Violations of anti-bribery laws (including the Foreign Corrupt Practices Act (FCPA) and applicable local laws) will be reported to authorities.

8. ENVIRONMENTAL RESPONSIBILITY

Manufacturing carries real environmental obligations. We take them seriously.

• All employees must comply with environmental laws and the Company’s environmental policies.

• Hazardous materials must be handled, stored, and disposed of according to applicable regulations (including EPA requirements).

• Spills, releases, or environmental incidents must be reported immediately.

• We are committed to reducing waste, conserving energy, and continuously improving our environmental performance.

• Falsifying environmental records or permits is a serious violation and may carry legal consequences.

9. SUPPLY CHAIN & VENDOR CONDUCT

We hold our suppliers and contractors to the same ethical standards we apply to ourselves.

• Vendors and contractors must comply with applicable labor laws, safety regulations, and human rights standards.

• We prohibit the use of forced labor, child labor, or human trafficking in our supply chain.

• Procurement decisions must be made on merit, value, and quality — not personal relationships or improper incentives.

• Employees involved in procurement must disclose any personal relationships with vendors.

10. COMPANY ASSETS & RESOURCES

Company equipment, tools, materials, vehicles, and facilities are provided for business use.

• Employees must handle Company property with care and promptly report any damage or theft.

• Theft or unauthorized removal of Company property — including materials, scrap, or products — is grounds for termination and may result in criminal prosecution and civil litigation.

• Company systems and communications (email, computers, networks) must be used responsibly and primarily for business purposes.

11. CONFIDENTIALITY & PROPRIETARY INFORMATION

Manufacturing processes, formulas, designs, customer lists, pricing, and operational data are Company assets.

• Employees must protect confidential information from unauthorized disclosure, both during and after employment.

• Proprietary information may not be shared with competitors, former employers, or third parties without authorization.

• Employees must comply with any non-disclosure or confidentiality agreements they have signed.

• Employees must not reveal tolling partners to anyone outside of the Company.

12. FINANCIAL INTEGRITY & ACCURATE RECORDS

• All financial transactions, time records, expense reports, and production data must be recorded accurately and honestly.

• No employee may falsify records, approve fictitious transactions, or submit fraudulent claims.

• Suspected fraud or financial misconduct must be reported to Management immediately.

• We cooperate fully with internal and external audits.

13. REPORTING CONCERNS & NON-RETALIATION

We encourage all employees to speak up when something doesn’t seem right.

How to Report:

• Speak directly with your supervisor or Management

Non-Retaliation: The Company strictly prohibits retaliation against any employee who reports a concern in good faith. Retaliation is itself a violation of this Code and will result in disciplinary action.

14. ENFORCEMENT & CONSEQUENCES

Violations of this Code will be investigated promptly and may result in:

• Verbal or written warning

• Mandatory retraining

• Suspension with or without pay

• Termination of employment

• Civil or criminal referral to appropriate authorities

Severity of consequences will reflect the nature of the violation and any prior disciplinary history.

ONE-PAGE QUICK REFERENCE

WERNER G. SMITH, INC. CODE OF BUSINESS ETHICS

★ OUR CORE VALUES

Safety First — Never compromise on health, safety, or community

Accountability — Own your actions and the outcomes of your work

Quality — Hold yourself to the highest production standards

Integrity — Honest and transparent in all business dealings

Respect — Treat every person with dignity

Sustainability — Minimize environmental impact; preserve resources

✔ ALWAYS DO

► Follow all safety rules, wear required PPE, and report injuries or hazards immediately

► Produce accurate, conforming products — report defects and never falsify quality records

► Treat all colleagues with dignity; harassment or discrimination will not be tolerated

► Record time, expenses, and production data honestly and accurately

► Protect confidential information, tolling partners, trade secrets, and proprietary formulas at all times

► Report concerns — you are protected from retaliation for good-faith reporting

✘ NEVER DO

► Bypass, disable, or override safety equipment or procedures — ever

► Knowingly pass, ship, or conceal defective or non-conforming products

► Accept or offer cash, gifts, or kickbacks intended to influence business decisions

► Use, share, or disclose confidential Company information without authorization

► Steal, misuse, or remove Company property, materials, scrap, or products

► Falsify any record — financial, environmental, quality, safety, or production

If something doesn’t seem right — speak up. Ask your supervisor or contact Management.

Violations may result in disciplinary action up to and including termination and legal referral.

Revised 5-7-26

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